NAB Files Petition to Correct Television White Space Database Design Flaws

The National Association of Broadcasters filed a petition today with the Federal Communications Commission requesting a rulemaking to correct serious design flaws in the television white spaces (TVWS) database system.

NAB also filed an emergency motion to suspend operations of the TVWS database pending completion of the rulemaking or until temporary methods to ensure accurate database information were adopted.

The television white spaces database is designed to monitor where and when unused areas of the broadcast TV spectrum band may be used by an unlicensed device. NAB conducted multiple analyses of the database system over the past year and found unlicensed device users provided inaccurate information in all nine of the required fields of the database, including invalid FCC IDs, fake serial numbers and false contact information. Most problematically, the analyses found that more than one-third of fixed TV white space devices in the database listed erroneous, and occasionally wildly inaccurate, location data.

“Whether users are misusing the database because of concerns over providing their actual location, willful circumvention of the rules to operate on more channels than permitted, or sheer laziness, the result is the same: The significant number of false entries undercuts the integrity of the database and defeats its intended purpose,” said NAB in its petition.

NAB also called for the FCC to temporarily put a hold on database operations until fixes were implemented. NAB suggested establishing a temporary emergency certification mechanism requiring white space device users to attest the accuracy of their information or face FCC sanction for inaccuracies that are not quickly corrected.

“After several years of operation, the database plainly lacks effective safeguards to ensure its reliability in either preventing interference in the first place or supporting Commission enforcement action if needed,” said NAB. “Given the database’s systemic flaws, the Commission should act on an emergency basis to immediately suspend its operation until the agency can verify that all new entries are complete and reliable. This suspension need not be onerous or prolonged.”

NAB requested the FCC amend the TVWS database rules in two ways to ensure reliability and effective enforcement. First, according to the petition, the Commission should eliminate the “professional installer” option and instead require that every fixed and mobile device include incorporated geolocation capability, like GPS. Second, the FCC should implement real and effective accountability measures not only for parties registering a white space device but also for database administrators, which includes multinational corporations such as Google.

“Preventing interference and ensuring the efficient, rather than chaotic, use of spectrum is a core FCC responsibility, dating back to the establishment of the Federal Radio Commission in 1927,” said NAB. “Experience now shows that, when left to their own devices, many TVBD users routinely enter false location information, either through error or mischief. The FCC must revise its rules to solidify a spectrum-sharing framework that functions for all operators in the TV bands – and that may serve as a model for sharing in other spectrum bands in the future.”

NAB strongly believes this petition should in no way cause the FCC to delay the broadcast spectrum incentive auction and supports the FCC’s goal of conducting the auction by early 2016.